Interpretation ID: aiam3904
Esq.
Dean Hansell
Esq.
Donovan Leisure Newton & Irvine
333 South Grand Avenue
Los Angeles
CA 90071;
Dear Messrs. Waimey and Hansell: I am responding to your correspondence regarding the definitions o 'convertible' and 'open-body type vehicle' under National Highway Traffic Safety Administration (NHTSA) safety regulations.; Your first question concerns the definition of 'open-body typ vehicle.' Our regulations provide a definition at 49 CFR S571.3: '...a vehicle having no occupant compartment top or an occupant compartment top that can be installed or removed by the user at his convenience.' The common usage of that term in our interpretations is that this term is intended to apply to multipurpose passenger vehicles, such as Jeep-type vehicles. Thus, neither of the automobiles in the pictures you included with your letter (Porsche 911 Carrera Cabriolet and Porsche 911 Carrera Targa) are considered to be open-body vehicles.; You also ask whether the Porsche 911 Targa is considered a convertible You state that there is no fixed, rigid structural member joining the 'A' pillar with the 'B' pillar. Despite this absence, the Targa roof, beginning behind the 'B' pillar, apparently is a fixed, rigid structural member that meets Federal roof-crush standards.; You are correct in stating that our regulations do not expressly defin 'convertible.' NHTSA interpretations, however, have consistently defined 'convertible' as a vehicle whose 'A' pillar or windshield peripheral support is not joined with the 'B' pillar (or rear roof support rearward of the 'B' pillar position) by a fixed, rigid structural member. Thus, the Porsche 911 Targa is considered a convertible because it meets this definition. While the vehicle is therefore not required to meet the roof-crush standards, it is commendable that Porsche has designed it to do so.; If you have any further questions, please let me know. Sincerely, Jeffrey R. Miller, Chief Counsel